ILLINOIS
POLL4UTI:ON CONTROL
BOARD
December
20,
1984
IN THE MATTER OF:
)
ATLAS FORGINGS DIVISION OF
)
R83-34
SCOT
FORGE
PETITION FOR A SITE~
SPECIFIC
OPERATIONAL LEVEL PURSUANT TO
)
CHAPTER
8,
RULE
206(d) OF
THE
)
RULES
2~NDREGULATIONS
OF
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
)
ADOPTED
RULE,
FINAL
OPINION
AND
ORDER.
OPINION
AND
ORDER
OF THE
:BOARD
(by
B~.
Forcade):
On
August
2,
1984,
the
Board
proposed
to
adopt
a
new
rule,
35
IlL.
Adin,
Code
901.118,
which
provides
site—specific
relief
from
the
Board~s
noise
regu1ations~
First
notice
of
this
proposal
was
p~biished
at
8 Ill.
Reg,
15274,
on August 24, 1984.
The
first
notice
comment
period
expired on October
8, 1984.
The
Administrative Code
Unit
submitted
a
comment on September 10,
1984, regarding Illinois Register first notice format.
No other
comments were received~
The
Board
made
a non-substantive change
in the
wording
of
the proposed
rule.
By
order of the Board
dated
October
10,
1984,
the
proposed
rule
we
c
mi nfli
tt
ed
t
o
he
J
ii
-
Cu~u
u
cc
on
Admin
~.
s
ti
a : ~ve
R~
I ~
(“JCAR”)
JCAR
second
notice
review
commenced
on
October
22,
1984.
JCAR
is~ied
a
Certification
of
No
Objection
to
this
rule-
making
on
November
8,
1984.
This
matter
comes
before
the
Board
on
a
petition
filed
on
November
2
3
,
19 83,
by
Atlas
For~inq a
Divi sion
of
Scot
Forge
“Ati
a.s~)
for
a
sita~ spec
:L fir
oper itt
on ii
level
for
its
forging’
shop
as
an
alternative
to
c
pliacce
with
the
noise
limits
contained
in
35
II I
Adm
Code
9 01
105
ol
N
PU
Ia
206
of Chapl:er S
)
A
p~b1ic
hearing
was
held
on
rfa,:ch
29~
1984,
in
Hampshire,
Ii:Iinois,
This
hearing
was
scheduled
with
those
of
three
other
Illinois
forgin
shops
in
order
to
conserve,
the
time
and
resources
of
the
parties
involved,
No
pihiic
testimony
or
comments
were
received,
The Department of
Energy
and
Natural
Resources
(~‘DENR”)
issued
a
statement of
negative
declaration
of
economic
impact on
April
IL3
~S’1,
nbv~ata ~g
nr
an
economic
impact
stolement
The
Boaru
appreciates
the
contritctcrn
ci
David
G.
Mueller
who
assi
staN
in
dr aftang
this
Cr1 tics
On
July 18, 1984,
the Economic
and
Technical Advisory
Committee
concurred with the DENR~sfinding.
The regulatory scheme
for existing
forging
operations requires
that
the
Petitioner
(1)
comply with the
noise prohibitions
contained
in
Table
F
of
Rule
206(c)
no later
than fifteen months
following
the
effective
date of
the
Rule,
or
(ii)
seek a permanent site-specific
operational
level
as
provided
in
Rule 206(d),
These
rules have
been
recodified
as
35
Ill, Adm,
Code
901.905
(c) and
(d).
The
noise
prohibitions
in
§901,905(c) vary
for different
classes of
receivers
and
for
daytime
and
nighttime
periods,
A
petition
under
§901,905(d)
must
demonstrate
that
it is technically
and
economically infeasible
for
its shop
to meet the numerical
limits
of
§901.905(c),
A petition must also
propose measures
to reduce
impilsive
noise
where
possible
and
assess the consequential
health
and
welfare
impacts
on
the
airrounding community.
Atlas is located
at
1501
South
55th
Court,
Cicero,
Illinois.
The
Atlas
operation
occupies
1.37
acres
and is surrounded
on
the
north,
south and east by heavy industry.fi
To
the
west,
beyond
the
Petitioner~s
parking
areas,
are
residences
(R.
57—58).
The facility
was
built
in 1914 when the
surrounding
land
was
industrial or
vacant
(R,
56),
There
are
100
Class
A residences that
receive
forging noise
in excess of
the
regulatory limits
(Pet,
p.
8).
The
facility
consists of
several
buildings,
one
which
houses
three
forging
hammers
and
four
furnaces
(R.
58-60).
There
is
one
8,000
pound
hammer,
one
6,000 pound
hammer and one 4,000 pound
hammer
(R.
59).
This
building has
rolling doors and windows
that
are
usually open
during operation
and
a
steel
roof
with
numerous
ventilators
CR.
64).
Atlas currently
employs
40
people
(Pet,
p.
4).
The
forging
process
consists
of
heating
carbon
or
alloy
steel
in
furnaces
to
approximately
2350 degrees Fahrenheit and
then
forcing
the
heated
pieces
between
two
dies,
Atlas utilizes
open
dies
that
have no
pattern
(PU
60).
The
upper
die
is
attached
to
a
guided
ram
and the
lower
die
is attached to the
forge.
The
metal
is shaped through pressure exerted
by the
ram
or
forge
hammer,
The sound produced through this
process is
impilsive and
originates primarily from the impact between the upper
and lower
die
and
the
workpiece.
There
is
a constant
flow
of materials
between
the
furnace,
forge,
and
cooling
area
(PU
48).
Atlas
produces
forgings for the
gear,
machine
tool
and
energy industries
(Pet,
p.
4),
The
nathre
of
the
forge
operations
creates an extremely
hot
work environment.
The
furnaces
require
a
tremendous
amount of
oxygen
and
emit
a
great
deal
of
heat,
The cooling
workpieces
also
radiate
heat
into
the
forge
shop.
Consequently,
the
shop
requires extensive ventilation which
is provided
by the
ground
level
doors and windows and roof ventilators
(PU
64),
This system
creates a
~stack effect” whereby air flows
through the
open sides
of the
building
and
is
drawn
up
and
out
through the roof
CR.
64),
This
natural ventilation
system
is
effective
and
widely
utilized
by the
forging industry.
The
open
sides
of the building
also
facilitate
the free movement
of
material
in and
out
of
the forge
shop.
Noise escapes
through these roof and side openings.
Atlas
currently
operates its forging hammers from 7:00 a,m,
to 4:30 p.m.
four to six days per week
(R.
66).
Often they only
operate two of their three
hammers.
In
a post-hearing submittal,
Atlas
requests
an
operational
level
that would allow them to
operate between 6:00 a,m,
and 6:00
p.m. Monday through Saturday,
This level would allow some
flexibility
in their
operation in
case the need arose to work past 4:30 p.m.
(PU
67).
Production
has fluctuated over the last
few years.
Production levels have
declined since 1981
as
shown by the
table below,
The decline
in
production
is expected
to continue
in
1983.
The figures below
reflect approximations because of the nature of the open die
forging process
(R,
77).
Total
No,
of
forgings
No.
of
Tonnage
of
all
on
hammers
_____
~
~
1980
27,791
973,000
3,710
1981
35,384
1,238,000
4,665
1982
24,904
892,000
3,052
The
regulations of the Board define two methods of measuring
sound.
The definition
of dB(A),
or A
—
weighted
sound
in
decibels,
is found
in 35
Ill. Adm. Code 900,101,
as is the definition of
Leq,
or equivalent continuous
sound
pressure level
in decibels.
Essentially,
dB(A) measures
the
noise level at the peaks while
Leg measures the
average
noise
level
over time, including peaks
and background noise.
Permissible
impilsive
sound
levels
for existing
forge shops
are
found in
35
111.
Adm,
Code 901.105.
The impilsive sound
level
emitted to residences
(Class
A
land) cannot exceed 58,5
Leg,
during the day or
53.5
Leg
at
night.
Actual measurement of
sound
were taken around
the
Atlas
facility
by George
F. Kamperman,
an expert
in the area of
noise~control
engineering.
Based on
these
measurements, Kamperman predicted that the highest level
at
the
nearest receiver would be approximately 70 Leg CR.
116),
Approximately 100 Class A
residences
are
exposed to forging noise
in
excess
of
the regulatory
standard.
Seventy Leg is the maximum
or
~worst
case”
situation.
Atlas
has
received
no
citizen
complaints.
In
the
early
1970’s,
Atlas
received
complaints
from
Cook
County
regarding
noise
from
their
steam
exhaust,
Atlas
subsequently pit
a
silencer
on
their
steam
vent
CR.
70).
The
Illinois
Environmental
Protection
Agency
(~Agency”)
received
a
citizen
complaint
in
1976
about
the
forging
noise
from
Atlas,
Atlas
has
not
implemented
any
noise
reducing
measures
at
the
Cicero
facility.
They
have,
however,
built
a
new
plant
in
Wisconsin
that
utilizes
noiseless
presses
CR,
69).
Atlas
has
investigated
various
methods of compliance
with
the
Board’s
noise
regulations.
To
achieve compliance,
it
would
be
necessary
to
close
up
the
forge
shop,
by
replacing
all
windows
4
with double glazing, replacing
all
non-masonry surfaces
and
wall
surfaces
surrounding
windows and doors with more massive material s
and eliminating the large west
access-door opening entirely.
A
mechanical
ventilation
system
would have to be installed which
would
include
fans
and
silencers.
The
roof would
have
to
be
structurally
reinforced
to
support
this
additional
burden
(PU
71-72).
These
modifications
would
cost
approximately
$320,000
in
1979 dollars.
This figure
does
not
reflect
the
installation
costs,
operating costs or the
cost of reinforcing the roof
(H.
117).
Material
flow would
be
altered.
Productivity would probably
decrease due
to
the
enclosed
work environment
and
the
inhibited
material
flow patterns
that
would
result
(R,.
73).
Petitioner’s
president testified that if site—specific relief was not granted,
they
would
relocate their
three
hammers to their Wisconsin facility
(H.
74),
The
Agency,
in
their
written comments on the proposal
filed
January 26,
1984,
did
not challenge the Petitioner’s qualification
for site—specific relief
on the basis that it
is an “existing
impact forging operation,”
nor did they question the fact that the
Petitioner was violating Rule
206(C),
The Agency stated that
while technologically feasible
noise reduction measures existed
for
forge
shops,
these measures
were
not technically feasible or
economically reasonable for
Atlas,
The
Agency also stated
that
granting the proposed site—specific operational
level would not
endanger the hearing
of area residents,
The Board proposes granting the site—specific operational
level requested by Atlas,
Atlas is
an existing impact forging
operation which is presently
in
violation of §901.105(c),
While
compliance is technically
possible,
its extremely high cost makes
it
economically
unreasonable
for
Atlas
at this time.
On
a practical
level,
compliance
measures
would
decrease production by impeding
the
flow
of
materials
within
the
forge
shop,
create an unacceptable
work
environment
for the employees and result
in the closing
of
the
facility.
There is no danger of hearing loss to area residents,
The site-specific operational
level will be limited to three
hammers
that
may
operate
between
6:00
a,m,
and
6:00
p.m.
Monday
through Saturday.
No
specific
numerical
noise
level
limitations
are
being
imposed,
although
it
is
assumed
that
noise levels will approximate
those
testified
to
by
Atlas
and
its
witness,
Atlas should make
efforts to lessen noise
levels
in
the
future
as equipment is
replaced
and
new technology for
noise
suppression
becomes
available,
In
the
event
that
noise
levels
from
the
forge
shop
become
excessive,
citizens
have
the
right
to
initiate
proceedings
to
change
the
rule
which
accompanies
this
opinion.
The
operational
plan set
out
in
this order will
be
incorporated
into
35
Ill.
Adm.
Code
901.118.
Atlas will
be required
to
comply
upon
the
filing
of
the
rule
with
the
Secretary
of
State
of
Illinois,
62~84
The
Board
hereby
adopts
the following rule,
to
be codified
at
35
Ill. Mm.
Code 901.118,
and instructs the
Clerk to file the
rule
with
the
Secretary
of
State:
TITLE
35:
ENVIRONMENTAL PROTECTION
SUBTITLE
H:
NOISE
CHAPTER
I:
POLLUTION
CONTROL
BOARD
PART
901
SOUND EMISSION
STANDARDS
AND
LIMITATIONS
FOR PROPERTY
LINE~NOISE-SOURCES
Section 901.118
~
~onalLevel
~ForeDivisionofScotForeandfutureowners
of the
for in
facilit
located
at
1501
South
55th Court,
~~~L1no1s,
sa
specific
operational
level:
a)
Q~
ate
no~
an
thre~
or
in
hammers
at
any
one
time;
and
b)
Operate
its
forging
hammers
only between
the
hours
of
6:00
a~m,~~m~onda
through
Saturday
IT
IS
SO
ORDERED,
I, Dorothy N, Gunn,
Clerk of the Illinois Pollution Control
Board,
hereby
certify
that
the
above
Opinion
and
Order
was
adopted
on
the~~
day
of
~
1984
by
a
vote
of
Dorothy
N.
unn,
Clerk
Illinois
Pollution
Control
Board
62~85